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MCP and the 2-Hour Notification Process

December 12th, 2013 by Rick Cote, P.E., LSP

In a previous blog I introduced release notification requirements under the MCP. Depending on the type and severity of the release, there are three time frames for notifying MassDEP: 2-hour; 72-hour; and 120-day.

The 2-hour reporting time frame is for sudden, continuous, or intermittent releases of oil or hazardous materials to the environment. With few exceptions, MassDEP must be notified within two hours of obtaining knowledge of such release if any of the following are true:

  1. The release is equal to or exceeds a reportable quantity (310 CMR 40.0352 and 40.1600) and was released within a 24-hour period.
  2. The release (any quantity) causes a sheen on surface water.
  3. The release results in oil or hazardous materials found in a private drinking water well in concentrations greater than a reportable quantity (RCGW-1 reportable concentration in 40.1600).
  4. The release (any quantity) poses an imminent hazard as defined in 40.0321 and 40.0950 (includes explosion, fire, public safety and serious and immediate public health and environmental hazards).
  5. A release described in 1 or 4 above is indirectly discharged to the environment by means of discharge to a stormwater drainage system.
  6. A release described in 4 above is indirectly discharged into the environment by means of discharge to a sanitary sewerage system.

Additionally, MassDEP must be notified within two hours of knowledge of a threat of release to the environment if it is likely that it is about to occur at a quantity equal to or greater than the applicable reportable quantity or could pose an imminent hazard.

Once MassDEP is notified of a release, a RTN (release tracking number) is assigned to the site and written notification must be provided. Response actions to address the release must be taken after notification. For a 2-hour notification, this generally involves an Immediate Response Action (IRA). Look for my upcoming posts on 72-hour and 120-day reporting requirements.

For more information about CEI’s spill assessment and hazardous waste remediation services please contact Rick Cote, P.E., LSP directly at 800.725.2550 x302 or rcote@ceiengineers.com or Rebecca Balke, P.E. at rbalke@ceiengineers.com.  

Visit us at www.ceiengineers.com

Posted in the categories Hazardous Waste Remediation, MCP.